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The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad

Author

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  • John H. Mutti
  • Harry Grubert
Abstract
Migration of intangible assets from the United States to foreign countries has become easier due to the ability of U.S. firms to create hybrid entities in their affiliates abroad and to reach favorable cost sharing agreements with them. This strategy was particularly encouraged by the U.S. adoption of "check-the-box" regulations in 1997. Rather than receive royalties from affiliates abroad, US parent firms have an incentive to retain abroad in low-tax countries a greater share of the return to their US R&D. Evidence from several sources for years that span the 1997 policy change indicate a significant response by US corporations in utilizing this strategy. BEA data indicate affiliate earnings and profits grew more rapidly than royalty payments to US parents. Payments to U.S. parents for technical services rose even faster, as would be called for under cost sharing agreements. Regression analysis of affiliate data shows that parent R&D was a more important determinant of royalty payments to U.S. parents than it was for affiliate earnings and profits in 1996, but by 2002 it played a larger role in earnings and profits than in royalties. Cost sharing payments from affiliates in Ireland and from pure tax havens (Bermuda, the Cayman Islands, and Luxembourg) are particularly significant, both economically and statistically.

Suggested Citation

  • John H. Mutti & Harry Grubert, 2007. "The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad," NBER Working Papers 13248, National Bureau of Economic Research, Inc.
    • Handle: RePEc:nbr:nberwo:13248
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    References listed on IDEAS

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    1. Grubert, Harry, 2003. "Intangible Income, Intercompany Transactions, Income Shifting, and the Choice of Location," National Tax Journal, National Tax Association;National Tax Journal, vol. 56(1), pages 221-242, March.
    2. Rosanne Altshuler & Harry Grubert & T. Scott Newlon, 2000. "Has U.S. Investment Abroad Become More Sensitive to Tax Rates?," NBER Chapters, in: International Taxation and Multinational Activity, pages 9-38, National Bureau of Economic Research, Inc.
    3. Robert E. Baldwin & Robert E. Lipsey & J. David Richardson, 1998. "Geography and Ownership as Bases for Economic Accounting," NBER Books, National Bureau of Economic Research, Inc, number bald98-1.
    4. Bloom, Nick & Griffith, Rachel & Van Reenen, John, 2002. "Do R&D tax credits work? Evidence from a panel of countries 1979-1997," Journal of Public Economics, Elsevier, vol. 85(1), pages 1-31, July.
    5. Rosanne Altshuler & Harry Grubert, 2005. "The Three Parties in the Race to the Bottom: Host Governments, Home Governments and Multinational Companies," CESifo Working Paper Series 1613, CESifo.
    6. John Mutti & Harry Grubert, 1998. "The Significance of International Tax Rules for Sourcing Income: The Relationship between Income Taxes and Trade Taxes," NBER Chapters, in: Geography and Ownership as Bases for Economic Accounting, pages 259-284, National Bureau of Economic Research, Inc.
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    Cited by:

    1. Dischinger, Matthias & Riedel, Nadine, 2011. "Corporate taxes and the location of intangible assets within multinational firms," Journal of Public Economics, Elsevier, vol. 95(7-8), pages 691-707, August.
    2. Cooper, Maggie & Nguyen, Quyen T.K., 2020. "Multinational enterprises and corporate tax planning: A review of literature and suggestions for a future research agenda," International Business Review, Elsevier, vol. 29(3).
    3. Sarah Clifford, 2017. "Taxing multinationals beyond borders: financial and locational responses to CFC rules," EPRU Working Paper Series 17-02, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
    4. Dischinger, Matthias, 2010. "Multinational Enterprises and Corporate Taxation," Munich Dissertations in Economics 11147, University of Munich, Department of Economics.
    5. Kevin S. Markle & Douglas Shackelford, 2009. "Do Multinationals or Domestic Firms Face Higher Effective Tax Rates?," NBER Working Papers 15091, National Bureau of Economic Research, Inc.
    6. Markle, Kevin S. & Shackelford, Douglas A., 2012. "Cross-Country Comparisons of Corporate Income Taxes," National Tax Journal, National Tax Association;National Tax Journal, vol. 65(3), pages 493-527, September.
    7. Cooper, Maggie & Nguyen, Quyen T.K., 2019. "Understanding the interaction of motivation and opportunity for tax planning inside US multinationals: A qualitative study," Journal of World Business, Elsevier, vol. 54(6), pages 1-1.
    8. Kevin S. Markle & Douglas A. Shackelford, 2011. "Cross-Country Comparisons of Corporate Income Taxes," NBER Working Papers 16839, National Bureau of Economic Research, Inc.
    9. Clifford, Sarah, 2019. "Taxing multinationals beyond borders: Financial and locational responses to CFC rules," Journal of Public Economics, Elsevier, vol. 173(C), pages 44-71.
    10. Dischinger, Matthias & Riedel, Nadine, 2008. "Corporate Taxes, Profit Shifting and the Location of Intangibles within Multinational Firms," Discussion Papers in Economics 4450, University of Munich, Department of Economics.
    11. Richardson, Grant & Taylor, Grantley & Lanis, Roman, 2013. "Determinants of transfer pricing aggressiveness: Empirical evidence from Australian firms," Journal of Contemporary Accounting and Economics, Elsevier, vol. 9(2), pages 136-150.
    12. Griffith, Rachel & O'Connell, Martin & Miller, Helen, 2011. "Corporate taxes and the location of intellectual property," CEPR Discussion Papers 8424, C.E.P.R. Discussion Papers.
    13. Atif Mian & Amir Sufi, 2011. "Consumers and the economy, part II: Household debt and the weak U.S. recovery," FRBSF Economic Letter, Federal Reserve Bank of San Francisco, issue jan18.

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    More about this item

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm

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